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2018 (6) TMI 957 - AT - Income TaxReopening of assessment u/s 147 - notice u/s 148 - additions made for unexplained credit - Held that:- The peak credit statement is prepared by the assessee on the basis of the entries found in the pen drive and accepted by the Tribunal in earlier years [2013 (7) TMI 30 - ITAT DELHI] therefore, same method shall have to be followed in assessment year under appeal - Tribunal has given benefit of opening balance of the earlier years and that assessee had paid tax on the peak credit for AY 2003-04 - therefore, such amount shall have to be reduced from the peak calculated by the assessee and benefit of the same shall have to be granted to the assessee - issue of the peak is, therefore, fully covered by the earlier years orders of the Tribunal - in earlier years also Tribunal has dismissed the ground of appeal of the assessee as regards reopening of the assessment u/s 148 of the Act. Therefore, these grounds of appeal of the assessee are dismissed - hence we direct the AO to make an addition of ₹ 1,36,42,861/- on account of peak credit
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